SecProbe.io

Filing text and metadata
Intelligence Terminal Search Probe Scores Topics IPO Watchlist Monthly Activity About API

SEC Company Response from U S PHYSICAL THERAPY (USPH) — Sep 21, 2021

U S PHYSICAL THERAPY INC /NV (USPH) (CIK 0000885978)
Date: Sept. 21, 2021 · CIK: 0000885978 · Accession: 0001140361-21-031894

AI Filing Summary & Sentiment

File numbers found in text: 001-11151

Referenced dates: August 10, 2021, September 8, 2021

Date
September 21, 2021
Author
/s/ Carey Hendrickson
Form
CORRESP
Company
U S PHYSICAL THERAPY INC /NV (USPH) (CIK 0000885978)

Letter

VIA EDGAR Division of Corporation Finance Office of Life Sciences U.S. Physical Therapy, Inc. Form 10-K For The Fiscal Year Ended December 31, 2020 Filed March 1, 2021 Form 8-K Dated August 5, 2021 File No. 001-11151

Dear Mr. Cascio and Ms. Lochhead:

U.S. Physical Therapy, Inc. and its subsidiaries, (the “Corporation,” “we,” “our” or “us”) hereby transmits the Company’s response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated September 8, 2021, regarding its Form 10-K For The Fiscal Year Ended December 31, 2020 and filed with the Commission on March 1, 2021. For the Staff’s convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response.

Form 10-K For The Fiscal Year Ended December 31, 2020

Item 6.

Management's Discussion and Analysis of Financial Condition and Results of Operations, Results of Operations, Fiscal Year 2020 Compared to Fiscal 2019, page 31

1.

We reference your response to prior comment 1 in our letter dated August 10, 2021.

Please also revise future filings to clearly label "Gross profit, excluding closure costs" and "Operating costs, excluding closure costs" as non-GAAP within the table reconciling the above mentioned non-GAAP measures to the related GAAP measures. We reference the example of the format you have provided in your response.

1. Response:

In light of the Staff’s comment, in future filings, we will clearly identify the non-GAAP measures as such:

Gross profit, excluding closure costs (a non-GAAP measure),… and Total operating costs, excluding closure costs (a non-GAAP measure)…within the table reconciling the abovementioned non-GAAP measures to the related GAAP measures.

An example of the format is below:

For the Year Ended

December 31, 2020

December 31, 2019

Gross profit

Physical therapy clinics

$

82,609

$

102,808

Management contracts

1,755

1,287

Industrial injury prevention services

10,086

8,379

Gross profit

$

94,450

$

112,474

Physical therapy operations - closure costs

3,931

Gross profit, excluding closure costs (a non-GAAP measure)

$

98,381

$

112,499

We will prepare a comparable table reconciling the Total operating costs, excluding closure costs (a non-GAAP measure) to the related GAAP measure – Total operating costs.

We acknowledge that our Company and Management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

We thank the Staff for its review of the foregoing and the Form 10-K for the Fiscal Year Ended December 31, 2020. If you have further comments, please feel free to contact me at Chendrickson@usph.com or by telephone at 713-297-7000.

Sincerely,
/s/ Carey Hendrickson

Show Raw Text
CORRESP
1
filename1.htm

        VIA EDGAR

        September 21, 2021

        U.S. Securities and Exchange Commission

        Division of Corporation Finance

        Office of Life Sciences

        100 F Street, NE

        Washington, D.C. 20549

        Attn: Brian Cascio, Accounting Branch Chief, and Kristin Lochhead

                Re:

                U.S. Physical Therapy, Inc.

                  Form 10-K For The Fiscal Year Ended December 31, 2020 Filed March 1, 2021

                  Form 8-K Dated August 5, 2021

                    File No. 001-11151

        Dear Mr. Cascio and Ms. Lochhead:

        U.S. Physical Therapy, Inc. and its subsidiaries, (the “Corporation,” “we,” “our” or “us”) hereby transmits the Company’s response to the comment letter received from the staff
            (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), dated September 8, 2021, regarding its Form 10-K For The Fiscal Year Ended December 31, 2020 and filed with the Commission on March 1, 2021. For the Staff’s
            convenience, we have repeated below the Staff’s comments in bold, and have followed each comment with the Company’s response.

        Form 10-K For The Fiscal Year Ended December 31, 2020

                  Item 6.

                  Management's Discussion and Analysis of Financial Condition and Results of Operations, Results of Operations, Fiscal Year 2020 Compared to Fiscal 2019, page 31

                1.

                We reference your response to prior comment 1 in our letter dated August 10, 2021.

                  Please also revise future filings to clearly label "Gross profit, excluding closure costs" and "Operating costs, excluding closure costs" as non-GAAP within the table reconciling the above mentioned
                    non-GAAP measures to the related GAAP measures. We reference the example of the format you have provided in your response.

      1. Response:

        In light of the Staff’s comment, in future filings, we will clearly identify the non-GAAP measures as such:

        Gross profit, excluding closure costs (a non-GAAP measure),… and Total operating costs, excluding closure costs (a non-GAAP measure)…within the table reconciling the abovementioned non-GAAP
          measures to the related GAAP measures.

        An example of the format is below:

              For the Year Ended

              December 31, 2020

              December 31, 2019

              Gross profit

              Physical therapy clinics

              $

              82,609

              $

              102,808

              Management contracts

              1,755

              1,287

              Industrial injury prevention services

              10,086

              8,379

              Gross profit

              $

              94,450

              $

              112,474

              Physical therapy operations - closure costs

              3,931

              25

              Gross profit, excluding closure costs (a non-GAAP measure)

              $

              98,381

              $

              112,499

        We will prepare a comparable table reconciling the Total operating costs, excluding closure costs (a non-GAAP measure) to the related GAAP measure – Total operating costs.

        We acknowledge that our Company and Management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

        We thank the Staff for its review of the foregoing and the Form 10-K for the Fiscal Year Ended December 31, 2020. If you have further comments, please feel free to contact me at Chendrickson@usph.com or by telephone at 713-297-7000.

              Sincerely,

              /s/ Carey Hendrickson

              Carey Hendrickson, Chief Financial Officer

              U.S. Physical Therapy, Inc.